Thursday, August 02, 2007

Cat out of the bag.

Cemex case for tyre burning NOT PROVEN! Of course while the Jury was out both Cemex and the Agency refused to give the public any emissions data.

Now why could that possibly be?

Because the Agency Emissions Report of 4th April 2006 now at last finally revealed, to a very suspicious public, actually shows what we said all along - there is no proof that tyre burning improves emissions. In fact there is more proof to the contrary! It makes some emissions worse!

ALcontrol Laboratories were contracted, number 11812, to take the periodic samples of coal and tyre burning emissions for the Agency.
These were supposed to be the proof of the tyre trials much heralded "environmental improvement"!

In fact coal burning seems cleaner.

Nitrogen dioxide 841and 472Mg/m3

Nitrogen dioxide 459 and 540mg/m3

COAL - particulate 12.6; 18.8; 18.1; 16.5 mg/m3
TYRES - particulate 30.0; 43.4; 26.0; 30.0 mg/m3.

COAL - TOC as carbon 5.0; and 2.7;
TYRES - TOC as carbon 13.5 and 13.1;

COAL - TOC as toluene 5.48 and 2.9;
TYRES - TOC as toluene 14.8 and 14.4;

COAL - benzene 32.1; 0.1; 157; 43;
TYRES - benzene 88.2; 220; 110 ; 56;

In particular they claimed that the nitrogen dioxide was reduced by 25%. A funny calculator they used? Now they use the "claimed success" of the 2005 tyre trials to increase by 100% the burn rate, to 6 tonnes an hour, with the possibility of two further increments. And also to burn household and commercial waste - possibly to be
sourced from Holland as their waste is of a higher quality - suitable for getting good "trial" results.

Cemex' letter to the Agency 28 June 2007 says that they still cannot meet the Improvement Condition to reduce NOX from 800 to 500 mg/m3 which was required in the original Permit - by August 2005.
They ask for another extension to August 2008. They grumble about the low allocation of CO2 in Phase 2 of the EUETS, and cite that as a reason to burn increasing amounts of biomass. They claim the monthly NOX without tyres averaged 779mg/m3, with tyres April-June 2007 averaged 611mg/m3 - a 21.6% reduction.
But their own monthly emissions reports appear not to concur with this claim. "We anticipate a further reduction in oxides of nitrogen, although it cannot be guaranteed to be on a scale as seen previously."


"Due to insufficient supply of tyres 10 tonnes an hour could not be reached. It was envisaged at that time that perhaps 6 tonnes an hour would be achieved, and authorisation would be requested at that level. As it turns out, due to high levels of public interest, delays in permitting, and delays in undertaking the trial, only 3 tonnes an hour was achieved within the time constraints facing Cemex due to the Waste Incinerator Directive compliance date of December 2005. This issue was never foreseen in the original application due to the early date of that application."

It was only too well foreseen, and widely discussed at meetings, and the Primary Care Trust, RBC and consultees requested that Bag Filters be fitted as soon as possible to meet the criteria - ahead of their being "forced to fit them". And to reduce particulate emissions by hundreds of tonnes.
But Rugby Cement and the Agency argued strongly that bag filters would not work on this plant, would make emissions even worse, and that the ESPs were BAT (Best Available Technique) - that is until they were forced to meet the WID legislation, and to fit Bag Filters!

INTENTION TO BURN WASTE 100% OF TIME "subject to restrictions imposed by the WID which dictates periods when waste derived alternative fuels may not be used. Standby continuous emissions monitors will now be fitted to allow immediate switch over in the event of failure of any of the primary units.

This will minimise potential periods when waste derived fuels cannot be used and the feed has to be shut down, to periods covering start-up, shut-down, periods of feed less than 200 tonnes an hour, periods of malfunction and if emission limits are exceeded."

In short all the time when no emission limits apply! And what will happen to the nitrogen dioxide limits then? Nothing as they will not apply!

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